Harold and Kumar go to Comcastle

Save the Internet contests Laws of Physics

Comment The coalition of the frustrated who comprise Save the Internet! have filed a multi-trillion dollar complaint with the FCC regarding Comcast's blatant exercise of, um, reasonable network management. The key fact seems to be this: if you live in a dream world of secret manipulative forces, evil wizards, fire-breathing dragons, scary ghosts and freaky monsters, the actions of ordinary businesses seem peculiar.

The complaint is a combination of science fiction and group therapy, with generous doses of pure paranoia thrown in.

The FCC should act immediately to enjoin Comcast’s secret discrimination and, even before deciding the merits, issue a temporary injunction requiring Comcast to stop degrading any applications.

Secret discrimination? However, the same complaint describes Comcast's network management practices as blatantly violating the FCC’s Internet Policy Statement. So which is it, secret or blatant?

And it gets better. The basis of the complaint is the claim that Comcast discriminates against BitTorrent in particular and Peer-to-Peer file swapping applications in general. The FCC's principles say that customers can run any application they want, and BitTorrent is an application. Hence, limiting the bandwidth P2P can use is breaking the law.

There are only two problems with this line of reasoning:

1) P2P applications aren't the only ones that Comcast throttles. The complaint itself admits that classic ftp has problems when trying to act as a server on the Comcast network, and further charges that Comcast's management has much wider effects:

While only Comcast knows the algorithm they use to decide when to forge RST packets, it is unlikely that they ever tested the plethora of applications that are potentially broken by that algorithm.

2) BitTorrent isn't disabled on the Comcast network, not even the seeding mode where it acts as a file server. I'm a Comcast customer, and as I write this I'm seeding several video files from the current season of a certain murder mystery series set in the most dangerous county in England. The key fact about BitTorrent that the reporters have missed is that it typically takes hours for large file or set of files to transfer, so a five to ten minute test doesn't say anything.

It's a nonsense complaint.

Shoot first, ask questions later?

So we have to ask if the FCC should be issuing injunctions before deciding on the merits of completely meritless complaints?

In a way I wish they would, so that Comcast's customers could see what their network would look like without any traffic management. I'll predict an outcome: people swapping illegal videos would be thrilled, everybody else would be super-pissed. And if that harms Comcast's business, then it would certainly be reasonable for the complainants to be required to compensate them.

And finally, how is Comcast to manage those situations that arrive in the course of operating a network millions of times a day when the traffic bound for a certain path exceeds the capacity of the path without degrading any applications? Surely some applications are going to be degraded, assuming the network's capacity is, you know, finite.

And this brings us to the funniest part of the complaint, the helpful suggestions about how to manage the Comcast network:

...if Comcast is concerned that the collective set of users running P2P applications are affecting quality of service for other users on a cable loop, they could readily set dynamic quotas for each user on the loop, so as to ensure that there is always bandwidth available for users who are not running P2P applications – and they could do so without interfering in protocol choice

As far as we know, this is exactly what Comcast is doing, setting dynamic upload quotas and enforcing them by preventing excessive numbers of upload streams from starting inside their private network.

The angels apparently believe there's a magic "quota" knob inside each cable modem owned or rented by each Comcast subscriber, but that's not the case. These modems can take a hard cap at boot time, but after that they lack a mechanism to prevent them from issuing excessive numbers of upstream transfer requests. That's undoubtedly a flaw in the definition of the DOCSIS protocol, but it's one that isn't going away simply because we may earnestly wish it would.